ACCEPTED
06-14-00071-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
3/16/2015 3:06:06 PM
DEBBIE AUTREY
CLERK
No. 06-14-00071-CV
FILED IN
6th COURT OF APPEALS
IN THE COURT OF APPEALS FOR THE TEXARKANA, TEXAS
SIXTH DISTRICT OF TEXAS 3/16/2015 3:06:06 PM
DEBBIE AUTREY
AT TEXARKANA Clerk
IN THE INTEREST OF A. B. O. and E. B. O., Children
UNOPPOSED SECOND MOTION TO EXTEND TIME FOR FILING
BRIEF OF APPELLEE
TO THE HONORABLE COURT OF APPEALS:
Appellee, MELANIE McMURTRY, files this unopposed second motion
requesting an extension of time to file her Brief of Appellee and would show unto
the Court the following:
I.
Appellee’s brief was due to be filed on March 11, 2015.
II.
Appellee’s brief is now complete but counsel was unable to complete it by the
due date due to the following commitments:
1. Serving as mediator in Willie Casteel v. Texarkana Newspapers,
Inc., Cause No. 13-C-0804-202 in the District Court of Bowie
County, Texas;
2. Serving as mediator in Jerry Dudley v. Cody Creighton (Pre-
Litigation);
3. Serving as mediator in Krystal Riddle v. Bob Addison and Tisha
Addison, Individually and d/b/a Bounce-A-Lot, Cause No.
13C1199-202 in the District Court of Bowie County, Texas; and
4. Research for preparation of response to petitions for review in
Helen Butts-Tipps, Sue Ethel McEachern, and The Estate of
Flora L. Thompson, Perry Thompson, Jr., Independent Executor,
Perry Thompson, Jr. and Sandra Sue Sartain v. Chinn
Exploration Company, Chinn Family Limited Partnership and
Cherokee Royalty Syndicate Through its Receiver, Howard P.
Coughlan, No. 14-0958 in the Supreme Court of Texas.
Further, counsel for Appellee had a non-refundable prepaid family vacation the week
of March 9, 2015.
III.
Those obligations did not allow counsel adequate time to complete Appellee’s
brief by the due date. However, the undersigned counsel has completed Appellee’s
brief and it is being tendered for filing today, March 16, 2015.
IV.
Counsel, therefore, respectfully requests an extension of time to file Appellee’s
brief on the date of receipt.
WHEREFORE, PREMISES CONSIDERED, Appellee, MELANIE
McMURTY, respectfully requests that the Court grant this unopposed motion and
extend the deadline for her brief to the date of reception.
Unopposed Second Motion to Extend Time
for Filing Brief of Appellee – Page 2
Respectfully submitted,
/s/ John R. Mercy
John R. Mercy
Texas State Bar No. 13947200
MERCY p CARTER p TIDWELL, L.L.P.
1724 Galleria Oaks Drive
Texarkana, TX 75503
Telephone: (903) 794-9419
Facsimile: (903) 794-1268
E-mail: jmercy@texarkanalawyers.com
ATTORNEY FOR APPELLEE
CERTIFICATE OF CONFERENCE
I have contacted Lisa McPherson, Attorney for Appellant, regarding the relief
sought by this motion and she has no objection to the motion.
/s/ John R. Mercy
John R. Mercy
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Unopposed Second
Motion to Extend Time for Filing Brief of Appellee has been forwarded to:
Mr. Brent M. Langdon Email: blangdon@ldatty.com
Ms. Lisa McPherson Email: lisam@ldatty.com
LANGDON n DAVIS, LLP
5902 Summerfield, Ste. A
Texarkana, TX 75503
Unopposed Second Motion to Extend Time
for Filing Brief of Appellee – Page 3
Mr. Chad Cable Email: chadcable@yahoo.com
CHAD CABLE LAW OFFICES
323 Gilmer Street
Sulphur Springs, TX 75482
on this the 16th day of March, 2015.
/s/ John R. Mercy
John R. Mercy
Unopposed Second Motion to Extend Time
for Filing Brief of Appellee – Page 4